Regulatory Alerts2020-07-23 | Circular No.6Red Flags Indicators for Lawyers, Notaries and Independent Legal Professionals
Under the Anti-Money Laundering Act 2010, legal professionals are mandated to submit Suspicious Transactions Reports to the Financial Monitoring Unit for potential money laundering or terrorism financing activity. The provided red flag indicators serve as a tool to help identify suspicious behavior, though no single indicator definitively confirms illegal activity on its own. Professionals must evaluate these red flags in the context of a client's overall financial activity and profile to properly assess the risk of potential illicit activity.
FINANCIAL MONITORING UNIT (FMU) GOVERNMENT OF PAKISTAN 2ND FLOOR, SBP MAIN BUILDING, I.I. CHUNDRIGAR ROAD, KARACHI 4400
FMU-Circular No. 06 of 2020 July 23, 2020
DNFBPs (Lawyers, Notaries and Independent Legal Professionals)
Dear Sirs/Madams,
Red Flags Indicators for Lawyers, Notaries and Independent Legal Professionals
In terms of Section 7 (1) of Anti-Money Laundering Act, 2010, the reporting entities are required to promptly report Suspicious Transactions Reports (STRs) to Financial Monitoring Unit for potential Money Laundering (ML) / Terrorism Financing (TF) related activities.
The reporting entities also includes designated non-Financial Business Professions (Lawyers, Notaries and Independent Legal Professionals) as per Section 2 (u) read with Section 2 (m) of AML Act 2010.
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In order to identify a suspicion that could be indicative of Money Laundering (ML) or Terrorism Financing (TF), FMU has prepared the red flags indicators that are specially intended as an aid for Lawyers, Notaries and Independent Legal Professionals, which are attached as “Red Flags Indicators for Lawyers, Notaries and Independent Legal Professionals”.
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These red flags may appear suspicious on their own; however, it may be considered that a single red flag would not be a clear indicator of potential ML / TF activity.
However, a combination of these red flags, in addition to analysis of overall financial activity and client profile may indicate a potential ML / TF activity.
Encl: Red Flags Indicators for Lawyers, Notaries and Independent Legal Professionals.
Yours truly,
Sd/- (Sumera Baloch) Additional Director
Distributed to: The Secretary Ministry of Law and Justice The Attorney General Office of Pakistan